The CPW I-270/Westerville Road Clean Up Action Plan
As with our goals and strategies, the CPW Clean Up Plan is a work in progress. We will continue to evolve this plan. This clean-up plan can, and should be, used while our community is working to fully implement the Westerville Road Area (redevelopment) Plan.
The Westerville Road Area (redevelopment) Plan:
This plan was created in 2015 by Blendon Township and Westerville, and, as mentioned, is an exciting “new” vision of what this industrial site, and the area of Westerville Road near it, could be. You can view this plan on the CPW homepage, and sign your name in support of this 270/Westerville Road industrial site transformation. Our goal is to collect tens of thousands of signatures in support of this very important plan for our community.
The Clean Up Team
This team should consist of concerned citizens, a representative from various regulatory agencies, and concerned civic leaders and business owners. The Clean Up Team will work together in good faith, and with full transparency. The team should be given access to the site, and to site documents (save for proprietary information) that will help them understand the site better, clean up the site, and keep watch over the site.
Clean Up Thus Far
CPW has been working since April of 2013 to clean up this industrial site. Towards this end, we have brought some 30+ violation concerns to the regulatory authorities, and agency letters/violation notices have been issued. As long as citizens continue to report they are suffering from disruptive odors, dust, noise and truck traffic they associate with this industrial site, our clean-up work is not done. Below is the first outline of a Clean Up Plan.
Step by Step Process to Clean up the Industrial Site:
1. Conduct a complete audit/assessment of the industrial site, and the regulatory ins and outs of the site. Ensure every Co. at the site is utilizing the best available technology regarding pollution control equipment, AND the best management practices regarding pollution controls, etc.:
CPW has several concerns here—why is the concrete crushing plant not required to use a baghouse pollution control? Also, why is the Ohio EPA allowing concrete washout to go into unlined pits when the EPA Best Practice recommends lined pits? Also, could more technological controls be put on the asphalt plant, ie: covering all aggregate piles with an industrial aggregate pile tarp?
Action: Have clean-up team conduct walk-through of the site noting all emitting sources (particulate matter, noise, odors, leachate ponds, drains, outfalls, etc.), what pollution control technologies are being used, and/or could be utilized, etc.
2. Ensure all companies operating at the site have required permits, registrations, Storm Water Pollution Protection Plans, etc., and that these permits/registrations/etc. are all up to date:
CPW has uncovered violations in this realm. For instance, it was recently discovered that at least one of the companies operating at the site (Metro Materials reclaimed concrete crushing plant) had not secured the required OEPA water permit. Consequently, the company had not drafted the required pollution control plan, and was illegally discharging pollution into Alum Creek.
Action: Create a data base of all companies, and the required permits, registrations, etc. for each company (a check list of sorts), when the permit needs renewed, etc. Ensure all permits and/or registrations are secured and get renewed on time.
3. Review all Permits, Registrations, Storm Water Pollution Protection Plans, Emissions Formulas, etc. to ensure they are accurate portrayals of each companies’ facility, production levels, etc.:
Many of the air contaminant emissions at this site are not measured, they are calculated via an air pollution formula. The companies fill in these formulas with their own math, and turn these into the OEPA. Hopefully the OEPA always reviews these permits with a fine-tooth comb, AND always visits the site to ensure that all the math has been properly inputted into the formulas, is up to date, etc. IF input is underestimated, or, changes are made at the site and the formulas are not modified, etc., the emission information would be inaccurate. Also, why is Anderson Concrete allowed to operate with a “Registration Status” permit vs. a PTIO? Why is the Scioto Materials’ asphalt plant not accounting for their RAP crushing emissions? Is this because they contract this crushing out to a different company? Identify any emission loopholes?
Action: Create a binder complete with all site permits, registrations, SWPPP, etc. and review
Action: Analyze each companies’ emission formulas for accuracy
Action: Review all permits, registrations, SWPPP, formulas, etc. Become very familiar with these documents, and the site, to ensure the docs match the reality on the grounds.
4. Ensure all requirements of the permits, registrations, etc. are being carried out by each company, ie: all annual reports are being submitted, all pollution controls are being implemented, visual storm water testing is being done, etc.:
CPW has discovered violations in this realm. It was recently discovered, for instance, that Anderson Concrete had not conducted their visual water sampling, or, their benchmark water monitoring.
Action: Create a data base that lists when reports are due, and keep track.
Action: Create a data base of what pollution controls are required to be carried out by each company, etc., and schedule CPW Site Watch members (like a block watch) to do periodic visits to the site to check if pollution controls are indeed being implemented.
5. Analyze how the site has evolved, and how emissions/discharges have changed over the 20/25 years, etc. and why:
6. Conduct unannounced air testing of particulate matter emitted from site for levels AND its composition, ie: silica, fly ash, slag, asbestos, PAHs, etc., AND chemical water analysis as well:
7. Work to install a continuous air emission monitoring system at the industrial site:
8. To place a moratorium on any changes to site, or, site permits that would allow for any increased air emissions:
9. IF 1 through 8 does not meet CPW vision/mission, amend permits to reduce the overall production levels happening at this site:
10. IF 1 through 9 does not meet vision/mission, reduce the number of plants operating at this site:
11. IF 1 through 10 does not meet vision/mission, redevelop industrial site: